Epstein Secrets

15 statements about the defendant -- to be clear, because one of 16 the allegations is, of course, she was a madam and a 17 coconspirator with Epstein -- do involve Epstein. 18 THE COURT: Listen. Leave the pejorative out. Okay? 19 Please. 20 MS. McCAWLEY: Sure. 21 THE COURT: Simply because I

t, in 17 accord with the flight records, which have also been produced 18 in this case, which place Ms. on 23 flights with 19 defendant aboard Jeffrey Epstein's private plane. 20 So as these records actually show truancy, failed 21 grades, failure to complete courses, these should be excluded 22 under a

between our client and Mr. Dershowitz on page GM009, 24 it's one of the lies that our client specifically referred to. 25 She quotes statement, "Jeffrey bought me SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794613 59 H3V0GIU1 1 jewelry, diamonds were his favorite, and wonderful furn

in 8 this statement does she say, 'I didn't participate in this 9 abuse. I didn't know this person. I wasn't around. This 10 didn't happen with JE.' Instead, she picks statements and says 11 things like -- which sound like a jealous girlfriend -- she 12 says, "I called Jeffrey and told him I

0 EFTA00794568 14 H3VOGIU1 1 regularly with Mr. Epstein to other places. 2 So again, we didn't get to d

ipt, as you know. And in that 11 book manuscript, she describes that it was not her who took the 12 money from the tip jar, it was her boyfriend, Tony Figueroa, 13 and that's also what she testified during her deposition. 14 She said, for example, that she didn't commit the 15 theft, that he came in at

s nowhere in this statement does she say, 'I didn't participate in this abuse. I didn't know this person. I wasn't around. This didn't happen with JE.' Instead, she picks statements and says things like -- which sound like a jealous girlfriend -- she says, "I called Jeffrey and told him I've falle

or, in that the statements about the defendant to be clear, because one of the allegations is, of course, she was a madam and a coconspirator with Epstein -- do involve Epstein. aid al ir] COURT: Listen. Leave the pejorative out. Okay? Please. MS. McCAWLEY: Sure. THI Gl COURT: Simply because I'm

in fact, in accord with the flight records, which have also been produced in this case, which place Ms. Giuffre on 23 flights with defendant aboard Jeffrey Epstein's private plane. So as these records actually show truancy, failed grades, failure to complete courses, these should be excluded under all the rules I

client and Mr. Dershowitz on page GMOO09, it's one of the lies that our client specifically referred to. She quotes Virginia Giuffre's statement, "Jeffrey bought me SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011361 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24

21 22 23 24 25 14 H3VOGIU1 regularly with Mr. Epstein to other places. So again, we didn't get to depo

manuscript, as you know. And in that book manuscript, she describes that it was not her who took the money from the tip jar, it was her boyfriend, Tony Figueroa, and that's also what she testified during her deposition. She said, for example, that she didn't commit the theft, that he came in at the end of he

VIA EMAIL AND US MAIL Robert D. Critton, Jr. BURMAN, CRITTON, et 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Re: Mr. Critton: v. Jeffrey Epstein April 8, 2010 that he knows this old rich guy on Palm Beach .1 s for work that when he is in town In or around October of 2003, Tony Figueroa to

2010 that he knows this old rich guy on Palm Beach .1 s for work that when he is in town In or around October of 2003, Tony Figueroa took to Mr. Epstein's house. Tony said likes to get massages from young girls Ton told that if she gave Mr. Epstein a massage, he would pay her $300. Tony drove to M

West Palm Beach, FL 33401 Re: Mr. Critton: v. Jeffrey Epstein April 8, 2010 that he knows this old ri

or around October of 2003, Tony Figueroa took to Mr. Epstein's house. Tony said likes to get massages from yo

Jeffrey Epstein April 8, 2010 that he knows this old rich guy on Palm Beach .1 s for work that when he is in town In or around October of 2003, Tony Figueroa took to Mr. Epstein's house. Tony said likes to get massages from young girls Ton told that if she gave Mr. Epstein a massage, he would pay her $

51 H3ulgiva 1 in 2015, which is, all of these allegations that deal with 2 Jeffrey Epstein and Ghislaine Maxwell, all of those allegations 3 are untrue, she has the ability to know all of the public 4 information that would tell her thi

talked to people who think that comes under the transcript, who is then says: Well, you know, I know that were alleged as co-conspirators, and I Epstein's privilege. Mr. Edwards, in a party litigant, says: She wasn't a co-conspirator. That's what he says in this transcript, which you will see. He m

EFTA00794477 (212) 805-0300 EFTA00794478 57 H3ulgiva 1 MS. McCAWLEY: Well, we're entitled to ask her on the 2 stand; we're entitled to ask Jeffrey what he told her. 3 THE COURT: That's a different issue. That's a 4 different issue. I mean, that's a wholly different thing. 5 You're talking

laintiff's allegations that prior to ever meeting Mr. Epstein 3 or Ms. Maxwell, she was the victim of sex tra

second category of evidence we seek to introduce 19 at trial, your Honor, relates to testimony by her fianc 20 Michael Ostrich and her boyfriend Tony Figueroa. The facts on 21 this, your Honor, are that Ms. met Mr. Ostrich, he was 22 the brother of someone she was in rehab with, she was in drug 23 re

ed Testimony of Tony Figueroa Volume 2 September 8, 2016 Designated Testimony of Brittany Henderson (M) September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8) November 18, 2016 Designated Testimony of Ross Gow (Exs. 1-26) December 1, 2016 Designated Testimony of (Exs. 5-6, 9, 14) January

rson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

Designated Testimony of James Austrich June 24, 2016 Designated Testimony of Tony Figueroa Volume 1 (Ex. 1) June 24, 2016 Designated Testimony of Tony Figueroa Volume 2 September 8, 2016 Designated Testimony of Brittany Henderson (M) September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8)

05.10.18 Florida DAY.I.D. indindial Summary page for Janusz Banaslat WA 2021.04.12 3301011032 2006.05.01 Probabe Cause Alhdavn Regarding fencer Epstein 2021.04.12 3501411.003 2006.07.13 Palm Beach Police Oepartment Incident Report 2021.04.12 3501.011.001 2006.12.04 Law Enforcement Retort Rega

County Sheriffs OfficeWarm notification confirmation 2021.0412 3501.055401 2008.10.24 Pro Tech Monitoring. Inc.offender details report regardless Jeffrey Epstein 2021.01.12 3501.055102 2008.10.24 Notification letter to 2021.01.12 3501455.103 2008.10.24 Pro Tech Monitonng. Inc. offender details report r

21.04.12 3501.040011 2008.0410 letter from to Jeffrey Herman 2021.04.12 35014340012 2008.04.21 lett

a 3501.076033 2006.12.14 Florida DAY.I.D.$4dress information for To0y lteudoa 3501.076005 2006.12.14 Florida DAVID. inciMchaal summary page for Tony Figueroa 202L10.11 2021.10.11 ProducedtoDefense 2021.03.12 2021.04.12 2021.04,12 2021.01.12 2021.01.12 2021.01.12 2021.01.12 2021.01.12 2021.01.12

h 23 somebody from the government about, not only your 24 case, but about everything that's been in the media 25 and that's been publicized about Mr. Epstein in your MAGNA9 LEGAL SERVICES Page 7 1 case. 2 GHISLAINE MAXWELL: That's -- 3 TODD BLANCHE: Did he -- 4 GHISLA

ith 6 him to 2009, are you still working for Mr. Epstein 7 during that time? 8 GHISLAINE MAXWELL: So his -- so it'd be 9 true to say that Jeffrey tried very hard, he tried 10 very hard to -- to keep me to working for him, 11 because this is a complex operator. 12 I'm not talking abou

in the media 25 and that's been publicized about Mr. Epstein in your MAGNA9 LEGAL SERVICES Page 7 1 case.

, Tony, and then whoever 6 else underneath her. And that is how it started. 7 TODD BLANCHE: So before her -- 8 LEAH SAFFIAN: Tony Figueroa. 9 GHISLAINE MAXWELL: Tony Figueroa is her 10 boyfriend. 11 TODD BLANCHE: Before her -- so now going 12 back in the '90s. Yo

2 Min. 2/3/04 5:58 pm _ (c) I Min. 2/5/04 10:46 pm IEPSTEIN ARRIVES AT PBIA 2/7/04 4:44 pm (c) [17] Epstein house I Min. 2/9/04 4:52 pm EPSTEIN DEPARTS FROM PBIA 3/3/04 1:23 pm (c) 1 Min. 3/3/04 7:40 pm (c) Tony Figueroa I Min. 3/3/04 11:23 pm EPSTEIN ARRIVES AT PBIA 3/7/04 5:42

IA 2/7/04 4:44 pm (c) [17] Epstein house I Min. 2/9/04 4:52 pm EPSTEIN DEPARTS FROM PBIA 3/3/04 1:23 pm (c) 1 Min. 3/3/04 7:40 pm (c) Tony Figueroa I Min. 3/3/04 11:23 pm EPSTEIN ARRIVES AT PBIA 3/7/04 5:42 pm EPSTEIN DEPARTS FROM PBIA 3/11/04 11:20 pm EPSTEIN ARRIVES .AT PBIA 3/12/04